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| Request For
Comments on Proposed Standards and Policies Revisions |
OMRI has completed a proposed set of revisions to its standards and policies, and requests comments from the public on proposed revisions. Also, OMRI requests comments on a proposal to directly refer to the National Organic Program Rule as the standard used to review products for OMRI Listed status.
In 2007, OMRI issued a call for public comments on its existing standards and policies. During that public comment period OMRI received over 80 comments. OMRI took those comments and prepared the attached documents that propose revisions to the OMRI Standards Manual and OMRI Policy Manual. Not all comments were accepted. Some comments were not related to the standards or policies. Others would require a change in the organic standards or legislative action and are beyond OMRI’s capacity.
Proposed Revisions
- Proposal to Replace the OMRI Standards with the National Organic Standards
- Proposed revisions to current OMRI Standards Manual
- Proposed revisions to current OMRI Policy Manual
How to Comment
Comments must be received by OMRI by Wednesday, October 15, 2008.You may submit written comments by:
- Email to comments@omri.org,
- Fax to 541-343-8971,
- Courier to OMRI, 2495 Hilyard St., Suite B, Eugene, OR 97405, or
- U.S. mail to OMRI, P.O. Box 11558, Eugene, OR 97440-3758.
Discussion of Select Revisions to
Standards and Policies
Micronutrients
OMRI proposes to revise its standards for synthetic micronutrients that are permitted to be used with restrictions. One suggestion was to drop ‘iodine’ from the list of micronutrients acceptable as a plant nutrient, as that does not appear on the National List of synthetic substances allowed for crop production. Another was to strike out sodium molybdate and add molybdic oxide as a permitted molybdenum source. OMRI asks for public comment on these two proposals, as well as whether the list of micronutrients found at 7 CFR 205.601(j)(6) is an exhaustive list of permitted synthetic micronutrients. If commenters believe that other synthetic micronutrients may be used, OMRI requests that commenters specify which micronutrients are also permitted.
Please comment on the proposed revisions for ‘Micronutrients—Synthetic’ on page 4 in the OMRI Proposed Standards Manual Revision document linked below. Commenters are asked to provide references to scientific literature that can be used to support the case that these nutrients are essential elements for plant nutrition, at what levels plants would show symptoms of deficiency, document why nonsynthetic sources are able to overcome deficiencies. Commenters who want to have additional micronutrients and additional forms of already listed micronutrients permitted may want to consider submitting a petition to the National Organic Standards Board (NOSB) as well.
Pesticides
OMRI cannot currently list pesticides that are sold outside of the U.S. and are not registered with the U.S. Environmental Protection Agency (EPA). OMRI Standards should be changed to remove the U.S. EPA registration requirement for pesticides sold solely outside of the U.S., otherwise we risk losing international clients and credibility. In the Proposed OMRI Standards Manual Revision document linked above, in section 3.3 beginning on p. 16, major changes have been suggested to the pesticide review requirements and standards. Instead of requiring all pesticides to be registered with the EPA, the proposal will remove proof of registration requirements for pesticides and instead require that pesticides be either subject to registration, independent auditing, or subject to a requirement to disclose all ingredients on the product label.
Please comment on section 3.3 in the OMRI Standards Manual Revision document linked below. Specifically, do you agree that pesticide products sold solely outside of the U.S. should not be subject to U.S. EPA registration to achieve OMRI listing? Do you think that OMRI’s approach of requiring government registration, proof that the product is subject to independent audit, or disclosure of all ingredients on the label is comparable to OMRI’s current approach of requiring EPA registration?
Labeling
OMRI proposes to change its labeling requirements. Currently, OMRI lists products with labels that might not include instructions for use that are consistent with NOP rules. Certified organic operators may be at risk of losing their certification when they use OMRI Listed products that describe uses and applications that are not permitted under the NOP. OMRI proposes requiring that labels include use instructions that comply with the OMRI approved use. Please see section 2.8 in the OMRI Policy Manual Revisions to view the revision and comment.
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